. 2024 Jun;5:100369. doi: 10.1016/j.ssmqr.2023.100369

Table 2.

Comparison of key sections discussing alcohol advertising watersheds and minors’ exposure to alcohol advertising across versions if the AVMSD impact assessment report. The revised draft (dated 25 March 2016) did not discuss alcohol advertising rules. Emphasis added by the authors.

First draft of IA report (February 2016)	Final version of IA report (May 2016)
“Reinforcing the rules on alcohol advertising would have a positive impact on minors. In particular, a well-adapted watershed in peak time would prevent minors from being exposed to most of the alcohol advertisements. The study on minors' exposure to alcohol advertising showed that minors in most of the 9 selected Member States see most alcohol advertising in TV broadcasts during a certain peak hour. In the Netherlands, where a watershed is in place between 06:00 and 21:00, the average number of impacts for alcohol advertising seen by minors aged 4–14 during peak hour was lower than those in Germany, the UK or the Czech Republic which do not apply watersheds. This approach is supported by consumer organisations from the health sector in their replies to the public consultation. However, one pitfall of such watersheds may be a shift of alcohol advertising just after peak time, at a time when minors, although less numerous, are still watching television quite massively.” (p. 51) “As regards exposure of minors to alcohol advertising, the implementation of the related AVMSD provisions by some Member States has raised doubts as to their effectiveness. The study to measure minors' exposure to alcohol advertising shows that on TV broadcasting "on average, a minor in the EU saw 200 alcohol impacts and an adult over 450 during one year (2013)". The analysis revealed also that 87% of the television advertisements for alcohol contained at least one element that can be considered to be appealing to minors. […] Although alcohol advertisements are the least recalled type of advertisement by minors aged 9–17 in the nine selected Member States, 23.9% of these minors recalled having seen an alcohol advertisement online in the last month. 63% of the online advertisements (banners) for alcohol contained at least one element that can be considered to be appealing to minors.” (p. 7)	“Member States have been active in this domain in order to protect viewers, and in particular minors, from exposure to alcohol advertising: 24 of them have adopted stricter rules in this area and a number of them have defined the time before which alcohol advertising cannot be broadcast (i.e. watersheds). However, one major pitfall of such watersheds may be a shift of alcohol advertising just after peak time, at a time when minors, although less numerous, are still watching television quite massively. As the study on minors' exposure to alcohol advertising showed, when the time is not well adapted, minors may be exposed quite heavily to alcohol advertising just after the watershed. Moreover, given the divergences among Member States in peak viewing times for minors, when coupled with the COO principle, watersheds appear less efficient. The applicable watershed would be the one at the country of origin, while minors might be still watching TV in the country of destination.” (p. 12) “The study to measure minors' exposure to alcohol advertising shows that "on average, a minor in the EU saw 200 alcohol impacts and an adult over 450 during one year (2013)". This means that 1.8% of all advertising seen by minors (under age 18) in 2013 was for alcoholic beverages (as compared to 2.2%. for ads seen by adults). In other words, children are exposed to one impact every two days, and at nearly half the rate of adults. […] At the same time, the majority of countries have self- or co-regulatory schemes in place. Some of them are very efficient, while for others, there is scope for improvement.” (p. 12)

First draft of IA report (February 2016)

Final version of IA report (May 2016)

“Reinforcing the rules on alcohol advertising would have a positive impact on minors. In particular, a well-adapted watershed in peak time would prevent minors from being exposed to most of the alcohol advertisements. The study on minors' exposure to alcohol advertising showed that minors in most of the 9 selected Member States see most alcohol advertising in TV broadcasts during a certain peak hour. In the Netherlands, where a watershed is in place between 06:00 and 21:00, the average number of impacts for alcohol advertising seen by minors aged 4–14 during peak hour was lower than those in Germany, the UK or the Czech Republic which do not apply watersheds. This approach is supported by consumer organisations from the health sector in their replies to the public consultation. However, one pitfall of such watersheds may be a shift of alcohol advertising just after peak time, at a time when minors, although less numerous, are still watching television quite massively.” (p. 51)
“As regards exposure of minors to alcohol advertising, the implementation of the related AVMSD provisions by some Member States has raised doubts as to their effectiveness. The study to measure minors' exposure to alcohol advertising shows that on TV broadcasting "on average, a minor in the EU saw 200 alcohol impacts and an adult over 450 during one year (2013)". The analysis revealed also that 87% of the television advertisements for alcohol contained at least one element that can be considered to be appealing to minors. […] Although alcohol advertisements are the least recalled type of advertisement by minors aged 9–17 in the nine selected Member States, 23.9% of these minors recalled having seen an alcohol advertisement online in the last month. 63% of the online advertisements (banners) for alcohol contained at least one element that can be considered to be appealing to minors.” (p. 7)

“Member States have been active in this domain in order to protect viewers, and in particular minors, from exposure to alcohol advertising: 24 of them have adopted stricter rules in this area and a number of them have defined the time before which alcohol advertising cannot be broadcast (i.e. watersheds). However, one major pitfall of such watersheds may be a shift of alcohol advertising just after peak time, at a time when minors, although less numerous, are still watching television quite massively. As the study on minors' exposure to alcohol advertising showed, when the time is not well adapted, minors may be exposed quite heavily to alcohol advertising just after the watershed. Moreover, given the divergences among Member States in peak viewing times for minors, when coupled with the COO principle, watersheds appear less efficient. The applicable watershed would be the one at the country of origin, while minors might be still watching TV in the country of destination.” (p. 12)
“The study to measure minors' exposure to alcohol advertising shows that "on average, a minor in the EU saw 200 alcohol impacts and an adult over 450 during one year (2013)". This means that 1.8% of all advertising seen by minors (under age 18) in 2013 was for alcoholic beverages (as compared to 2.2%. for ads seen by adults). In other words, children are exposed to one impact every two days, and at nearly half the rate of adults. […]
At the same time, the majority of countries have self- or co-regulatory schemes in place. Some of them are very efficient, while for others, there is scope for improvement.” (p. 12)